Order of St. Benedict v. Steinhauser (1914)

In Order of St. Benedict v. Steinhauser, 234 U.S. 640 (1914), the Supreme Court ruled that the religious order was entitled to the estate of one of its deceased members, the author Augustine Wirth. State recognition of individuals’ rights to join, and thereby assume obligations to, religious societies arguably serves to protect the free exercise of religion guaranteed by the First Amendment.

Writing for the unanimous Court, Chief Justice Charles Evans Hughes found that Wirth had joined the New Jersey Order of St. Benedict voluntarily and had taken vows of “obedience, stability, chastity, and poverty.” The poverty vow included agreeing that monies he earned while a member would remain with the order. Although Wirth’s abbot had allowed Wirth to control some of his earned monies from publishing books, neither this permission nor the permission he had received to visit other monasteries altered the nature of the agreement he had made or opened Wirth’s estate to claims by others.

Hughes said that prior decisions had recognized “the distinctions between civil and ecclesiastical rights and duties.” Provided the order allowed members to withdraw, as the Benedictine Order did, the Court would enforce agreements by members to turn over their property to collective purposes. Hughes observed that in Wirth’s case, much of the value of his copyrights might even have stemmed from his association with the order.

This decision was similar to Baker v. Nachtrieb (1856), where the Court upheld a contractual agreement between individuals and a religious organization with which they chose to associate.

SEE ALSO

FURTHER READING

Silversmith, Jed Michael, and Jack Achiezer, Guggenheim. “Between Heaven and Earth: The Interrelationship between Intellectual Property Rights and the Religious Clauses of the First Amendment.” Alabama Law Review 52 (2001): 467–5